Subject: File No. S7-15-10
From: Richard F Dehner, CLU

August 4, 2010

I see no need to alter the basic structure of the current mutual fund C share class. It is already deeply imbedded in the mutual fund industry and client/advisor relationships and seems to be working well as anything else. The public has already decided on the appropriateness of the C share. Otherwise it wouldn't have survived this long. The free market has a way of deciding what works and what doesn't work. Clients aren't complaining about fees in the first place. Just the performance of the economy and the stock market in general. If modified, it will simply be replaced by a fee of a different name. The C share may not be the intended outcome of the old 12b-1 Rule but it has evolved as a logical answer to the critical needs of today's average American investor. Like it or not, there is an ongoing, and growing need for a variety of investment, retirement, and general financial planning services for the average American investor. As our world becomes more and more complex the expertise of an investment professional is needed more than ever. It will only get worse. There are so many products for the public to try and understand (e.g. Derivatives, EFT's, Variable Annuities). Plus they have to rely more and more upon their own skills and personal resources for retirement income as employers and state governments cut back on their defined benefit retirement plans. And they must continuously worry about the solvency of the Social Security System. Clients don't have the time, education, nor interest to do all that for themselves and are perfectly willing to pay a professional to do it for them. The C share was developed, in part, to address those kinds of investor needs. At issue are the ongoing .75 basis points of the C share. I personally feel that a good investment professional will earn that back for his clients in the form of returns the client would not have otherwise achieved on his own, as well as from ongoing general financial planning advice and services. I would speculate that the simple hand-holding and reassurance from a client's own personal advisor from time to time in this very uncertain world of ours is well worth the rest of the fee. This fee is really a small issue when you get right down to it. Just simply re-name it as a professional service fee and let the public decide when and where it's appropriate. Error on the side of conservatism and leave well enough alone. Don't create an even bigger problem. They have enough problems as it is.